Steve Window, Head of Safety at CNIM UK, and Claire Smith, Founder and Director at CLS Training & Consultancy Ltd, look at changes to the CDM Regulations and how the removal of Appendix 4 means there may be scope for flexibility surrounding training, without diminishing standards.
One of the many changes brought in by CDM 15 was the removal of Appendix 4 of the old ACoP, which, since 2007 had helped set the parameters for construction companies to define their training programmes.
The new guidance speaks of ‘skills, knowledge, experience and training’ (SKET) and encourages those appointing individuals or companies to ensure that anyone coming to work on site has the right qualities, to ensure that they perform their task safely.
This change could be significant, in two main ways:
Firstly, the bad news – there is the opportunity for it to go badly wrong. Poor assessment of SKET, or a move towards the cheaper (in the training element) rather than the most appropriate, could lead companies down a problematic route. Similar concerns were raised when the strict vetting of first aid training was removed by new legislation recently, although it is probably too early to say if that change has generated any unfortunate events.
Secondly, the more positive view. Current training in site safety – basic operatives safety cards – while generally very good and well policed by the overseeing bodies, has not been without its difficulties. These have been centred around administrative difficulties including booking courses at short notice, arrangement of translators, and a lack of cross-Europe recognition of UK qualifications.
Appendix 4 drove many companies down certain paths towards recognised qualifications. With Appendix 4 gone, there is scope for flexibility, without necessarily diminishing standards.
An example of what can now be done is the CLS course, produced at the request of a large European EPC with a significant pipeline of work in UK.
Using around 70% continental contractors, from many nations, the administrative challenge in ensuring the workers arrived on site with a recognised card was significant, and extra cost, delay and contractual disputes were not uncommon.The EPC contractor asked CLS, anticipating the CDM changes, to produce a course that would satisfy the requirement for demonstrably adequate training (the ‘T’ in ‘SKET’) but with a flexible approach to location, booking notice, translation and course numbers.
Between them EPC, CLS and TQUK (an Ofqual accredited body)are working together to offer operatives, supervisors and managers courses which will be recognised in Europe, therefore enabling the clients to move throughout the EU using known, approved and accredited courses.
The integrated risk approach addresses quality and environmental impact of work along with health and safety to create a more efficient workforce.
The qualifications, the first of their kind to be included on the official government register of qualifications, also achieve recognition across all European states allowing for a more cost effective and unified standard of training.
To sum up, whilst existing training courses are likely to remain the norm for many UK based companies, the opportunity offered by the change to CDM is for parallel developments in delivery of good training.
Safety managers should be aware of both the challenge and the benefits.
For more information about the CLS course, written by Technical Director, Karl Bater, visit : www.clstrainingltd.co.uk
Claire Smith is Founder and Director at CLS Training & Consultancy Ltd since 2013.
